Tom King’s CRM Plus --
Ruminations on "cultural resource management," environmental impact assessment, and related esoteric topics, by a curmudgeon who seldom has anything good to say about anything.

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Tuesday, April 27, 2010

Blowing Wind on Capitol Hill

I know I’m in a minority, but my guess is that when he makes his decision this week or next on the Cape Wind project, the Secretary of the Interior will say no. If this happens, it will almost certainly generate a great flurry of snorting, trumpeting and braying on Capitol Hill, with proposals to:

• Rein in the renegade Advisory Council on Historic Preservation by somehow constraining the range of things it can say in comments;

• Resurrect the tired old notion of having Section 106 apply only to formally registered properties; and even

• Undo Section 106 altogether.

The historic preservation community will predictably close ranks and defend the status quo.

Ho-hum. Business as usual. But is there any alternative? Any more creative way to react to the rhetorical gusts?

How about this? The real problem with Cape Wind, from the standpoint of Section 106 review, was that the Minerals Management Service (MMS), and hence the Cape Wind proponents, got lulled into thinking there was no big preservation issue involved; hence they ignored the real issues until it was too late to consult effectively and (perhaps) reach an agreeable compromise. This lulling resulted from two pieces of bad analysis:

1. The premise that the visual effects of the project on shore-side historic properties, being “only” visual, were “only” indirect impacts, and hence not that big a deal; and

2. The premise that the Sound, not being a “site” as ordinarily understood under National Register guidance, couldn’t be eligible for the National Register, and hence (disregarding all laws besides NHPA), didn’t have to be further considered as a cultural resource subject to impact.

Why did MMS get and pay attention to such dippy analyses? Well, there are probably lots of reasons having to do with the political situation at the time, the intelligence of the individuals involved, and so on, but I’d argue that a lot of it came about because we’ve all become so narrow-minded and compartmentalized in our thinking about environmental impacts. The CRM firm is hired to analyze impacts on “historic properties” or “cultural resources,” understood to mean archaeological sites, old buildings, and maybe landscapes. The environmental impact firm is hired to consider biological and social and maybe visual effects. One maybe provides input to the other’s report, or maybe the environmental guys just read the CRM report and put their own spin on it. Even if they are not subject to political or economic pressure to go light on the project’s impacts (and they probably are), they have neither the organizational structure nor much incentive to look at things in broad, interdisciplinary terms, to ferret out public concerns, and to explore alternatives as anything but window-dressing to make their reports look objective. So they don’t warn of impending train wrecks, and of course most of the time they get away with it, but every now and then, as in the Cape Wind case, the train really does go off the track.

The problem, in short, is that our system (sic) for environmental impact analysis has become unworkable and ineffective, especially where the cultural aspects of the environment are involved. That system needs a thorough overhaul. And it needs it not only to accommodate accelerated clean energy development, or homeland security, or whatever other development schemes float a particular congressperson’s boat, but to make the system work more efficiently, more effectively, less stupidly, and more in tune with the general public interest – including the interests of cultural resource management, broadly construed.

So I’d say to the historic preservation community (if it were listening; I don’t kid myself into thinking it is), don’t circle the wagons when the rampaging hordes come storming down the Hill. Welcome them, encourage them to sit down and reason together. Let’s have a study, let’s have a commission, let’s have hearings to examine not just how to get historic preservation out of the way of this year’s development fad, but how to make the whole environmental impact assessment process more sensible and responsible. I’m not so naïve as to think that this would necessarily have useful results – if just the usual suspects are involved (Interior, the ACHP, the National Trust, the Council on Environmental Quality), it probably won’t. But there’s just a chance that it would produce something useful, and it would beat spending another year or two at the barricades defending a status quo that probably, truth be told, isn’t worth the effort.

4 comments:

Anonymous
said...

I'd like to read Dr. King's thoughts and comments now that the Sec. of Interior has announced his approval of the Cape Wind energy project. I'm especially interested to hear thoughts about whether the recent BP oil spill in the Gulf coast region will impact this issue.

FYI: For the text of the Interior Secretary's decision, go to: http://www.doi.gov/news/doinews/upload/Nau.pdf

Well, it's obviously a good thing I'm not a betting man, since I called the SOI's decision precisely wrong. The near-simultaneous decision by the Air Force to withdraw its opposition to a windfarm in Oregon underscored just how powerful the windpower lobby is becoming. I'm skeptical of fads, including green fads, so though the SOI was certainly within his rights to approve Cape Wind, I have a feeling that some people -- at least those who have to live with the project -- will live to regret it.

The main thing I find interesting about the BP spill is that the rig was set up under a NEPA categorical exclusion. Perhaps, just perhaps, this will motivate the Fools on the Hill to consider reforming NEPA, and maybe such related authorities as NHPA, but it's probably unlikely.

Any thoughts on the Minerals Management Service reorganization announced by Sec. of Interior Salazar? I thought at first that the MMS was going to be divided into two separate agencies, one focused on leasing revenues and the other focused on inspection and regulatory oversight. Instead the MMS is proposed to remain as one agency, it will just have two divisions. The leadership of the agency will remain. All of this somehow pertains to historic preservation concerns because the MMS is also the source of revenues for the Historic Preservation Fund. These monies fund the ACHP, NATHPO, the National Park Service preservation programs and other NHPA mandated activities. The HPF is authorized to receive $150 million, but it only receives appropriations of perhaps 40% of this amount. MMS is also the federal agency that manages ACHP human resources matters such as pay, benefits, and also its administrative structure. My question is whether or not it matters that the MMS is the source of funding for the HPF? What will happen to the connections that MMS has to historic preservation in the new organization of the agency?

Anonymous' points about the MMS reorganization are interesting angles that I, for one hadn't thought about. Of course, reorganization is every agency's knee-jerk reaction to an embarrassment, and it appears that the jerk (sic) in this case is little more than a twitch. I shouldn't think it would have much effect on anything, least of all revenue for the HPF.

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About Me

Thomas F. King holds a PhD in anthropology from the University of California Riverside (1976), and has worked since the 1960s in the evolving fields of research and management variously referred to as heritage, cultural resource management, and historic preservation. He is particularly known for his work with Section 106 of the U.S. National Historic Preservation Act, and with indigenous and other traditional cultural places.

King is the author and editor of ten textbooks and tradebooks (See http://www.amazon.com/Thomas-F.-King/e/B001IU2RWK/ref=sr_tc_2_0?qid=1353864454&sr=1-2-ent) as well as scores of journal articles, popular articles, and internet offerings on heritage topics.His career includes the conduct of archaeological research in California and the Micronesian islands, management of academy-based and private cultural resource consulting organizations, helping establish government historic preservation systems in the freely associated states of Micronesia, oversight of U.S. government project review for the federal government’s Advisory Council on Historic Preservation, service as a litigant and expert witness in heritage-related lawsuits, and extensive work as a consultant and educator in heritage-related topics. He is the co-author of the U.S. National Park Service's government-wide guidance on "traditional cultural properties" (TCPs; see http://www.nps.gov/nr/publications/bulletins/pdfs/nrb38.pdf). He occasionally teaches short classes about historic preservation project review, traditional cultural places, and consultation with indigenous groups, and consults and writes as TFKing PhD LLC. Current major clients include several American Indian tribes and the U.S. Department of Veterans Affairs.